July 2, 2019

Lijia Ni
Chief Financial Officer
Oriental Culture Holding LTD
Room 1512 Block 4 Kang Yuan Zhihui Gang
No 50 Jialingjiang East Road
Jiangsu Province 210000
PRC

       Re: Oriental Culture Holding LTD
           Draft Registration Statement on Form F-1/A
           Amended on June 24, 2019
           CIK No. 0001776067

Dear Ms. Ni:

      We have reviewed your amended draft registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-1/A

Corporate History and Structure, page 3

1.     We note your response to prior Comment Two. Please revise to restore the
chart from
       your initial filing that you omitted from the amendment, so that the
company's corporate
       structure both as of the date of the prospectus, as well as upon
completion of the offering,
       are included in your prospectus. When you revise, please also reflect
that the dotted line
       between Outside PRC and Inside PRC should be adjusted to reflect that
Nanjing Rongke
       Business Consulting Service Co. Ltd., the WFOE, is inside the PRC.
 Lijia Ni
Oriental Culture Holding LTD
July 2, 2019
Page 2
Consolidated Financial Statements
Note 1 - Nature of business and organization, page F-7

2.    We note on May 8, 2019, Oriental Culture completed its reorganization of
entities under
      common control of various shareholders. Please explain to us the basis
for your
      conclusion that the entities in the reorganization were under common
control. As part of
      your response, please identify for us the significant shareholders of
China International
      Assets and Equity of Artworks Exchange Limited and Jiangsu Yanggu Culture
      Development Co., Ltd immediately prior to the reorganization and indicate
for us the
      percentage ownership that was held by each shareholder in each entity.
        You may contact Christie Wong, Staff Accountant, at 202-551-3684, or
Robert S.
Littlepage, Accounting Branch Chief, at 202-551-3361, if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Staff
Attorney, at 202-551-3415, or Celeste Murphy, Legal Branch Chief, at
202-551-3257 with any
other questions.



                                                           Sincerely,
FirstName LastNameLijia Ni
                                                           Division of
Corporation Finance
Comapany NameOriental Culture Holding LTD
                                                           Office of
Telecommunications
July 2, 2019 Page 2
cc:       Jeffrey Li
FirstName LastName